IRS Written Determinations
Free IRS private letter rulings, technical advice memoranda, and Chief Counsel advice with plain-English summaries and the official IRS release on every page.
No determinations match these filters
Try a different search term or clear the filters.
Member-owned cultural facility denied section 501(c)(3) status
A member-owned corporation sought section 501(c)(3) status for a building used for cultural events, meetings, rentals, and a separately operated for-profit bar. Its members each held an ownership shar…
Angel investor group denied section 501(c)(6) business-league status
An organization held monthly meetings where early-stage companies pitched investment opportunities to accredited members. It screened deals, coordinated due diligence, supported negotiations, and expe…
Charity lost its exemption after refusing to provide examination records
A section 501(c)(3) organization repeatedly refused to provide financial and activity information requested during an IRS examination. Its chief executive first said the initial request had not arrive…
Hospital charity lost exemption after selling its operations to for-profit buyers
A tax-exempt hospital organization stopped operating the hospital after the city that owned the facilities sold the hospital business and leased the facilities to for-profit buyers. The hospital busin…
Dissolved charity lost exemption after ignoring requests for records
State records showed that a section 501(c)(3) organization had been involuntarily dissolved. The IRS asked for descriptions of its activities, financial statements, minutes, publications, final return…
Social club lost exemption because restaurant rent exceeded the nonmember-income limit
A self-declared section 501(c)(7) social club provided members a place to socialize, play games, watch television, and hold holiday parties. It also continuously rented ground-floor space to an unrela…
Educators' club denied exemption because public banquet receipts were substantial
An association of women educators sought renewed section 501(c)(7) status after its prior group exemption was automatically revoked for three years of missed filings. Its main described activity was a…
IRS revoked charity that did not produce records for its audit
A section 501(c)(3) organization was selected for an audit of its operations and Form 990-N filing. The IRS sent repeated information requests and delinquency notices to the organization and its direc…
Charity lost exemption after failing to respond to repeated examination requests
A recently recognized section 501(c)(3) organization did not respond to repeated IRS efforts to examine its Form 990-N filing period. The IRS mailed several information requests and delinquency notice…
Group ruling holder lost exemption after withholding audit records
A section 501(c)(3) organization holding a group exemption was selected for an audit of its activities and Form 990-N period. The IRS sent certified requests to the organization and related individual…
Medical professional corporation denied exemption because its articles failed the organizational test
A professional service corporation formed to practice medicine applied for section 501(c)(3) exemption. A public charity controlled the corporation through its selected shareholder and a shareholder a…
Reinstatement denied for missing dissolution terms and unexplained donor-advised accounts
A nonprofit corporation sought reinstatement of section 501(c)(3) status after its prior exemption was automatically revoked for failing to file Form 990 for three consecutive tax periods. Its article…
Wellness collaborative denied exemption for promoting member businesses
A nonprofit formed by owners of five for-profit wellness businesses offered health fairs, classes, workshops, and wellness services at apartment complexes, stores, and its own meeting space. The activ…
Cannabis retailer denied section 501(c)(4) social welfare exemption
An organization originally formed as a nonprofit mutual benefit corporation to provide access to medical marijuana later restated its articles as a general stock corporation. It operated a public stor…
Member death-benefit organization denied exemption for serving private interests
An organization provided death benefits to the beneficiaries of active and retired members who died from any cause. Participating groups supplied the names of their participants, fees were based on th…
Death-benefit club denied section 501(c)(7) social-club exemption
A club’s only activity was providing death benefits to members to help with funeral costs. All income came from member dues, and all disbursements paid death benefits. The club had no social or recrea…
Referral network denied section 501(c)(6) business-league exemption
A mutual benefit corporation admitted only one member from each trade or specialty and held weekly meetings where members exchanged business leads, referrals, testimonials, and information about their…
Medical management service organization denied charitable exemption
A nonprofit successor to a for-profit company provided medical and administrative services to for-profit healthcare practices for ordinary fees, while also conducting incidental ministry activities su…
Housing assistance organization denied charitable exemption for defective articles
A nonprofit planned to renovate foreclosed homes and provide them rent-free to families while offering financial education and other support. Its original articles did not limit its purposes to charit…
Accounting consultants denied business league exemption
A membership organization for accounting businesses offered each member an initial free consultation followed by customized management consulting for quarterly fees. More than a redacted percentage of…
Medical marijuana patient aid organization denied charitable exemption
An organization planned to raise funds that dispensaries would use to provide a one-month supply of medical marijuana and transportation assistance to financially needy patients in a state program. It…
Member benefit fund denied Section 501(c)(3) exemption
A membership corporation sought Section 501(c)(3) status for a fund that provided financial or material assistance to members facing serious injury, illness, medical emergencies, terminal illness, or …
Charitable remainder unitrust denied Section 501(c)(3) exemption
A charitable remainder unitrust applied for separate exemption under Section 501(c)(3). During the settlor's and spouse's lifetimes, the trust was required to make annual payments to them, with the re…
Coffeehouse denied section 501(c)(3) status because of its commercial operation
An organization planned to operate a coffeehouse during normal commercial hours, charge prices generally matching nearby competitors, employ paid staff, and use common business advertising. It also pl…
Private-school scholarship procedures approved under section 4945(g)
A private foundation proposed scholarships for academically qualified students with financial need to attend accredited private schools in grades PK through 12. An independent committee would consider…
Exempt status revoked after organization failed to produce records
The IRS selected a section 501(c)(3) organization for examination to verify that its activities remained consistent with its exempt status. The organization did not provide requested records concernin…
Hospital district retained exemption and was reclassified as a governmental public charity
A hospital district had stopped directly operating a hospital after selling operating assets to a limited liability company and entering lease arrangements. The governing agreements reserved board app…
Charity reclassified after support shifted from fees to public contributions
A charity had originally been classified under section 509(a)(2) because fees were its primary source of support. Its support later shifted to gifts, grants, and contributions, and its reported public…
Social club exemption revoked for excessive nonmember investment income
A social club recognized under section 501(c)(7) reported that substantially all of its income for two examined years came from investments. Social clubs may generally receive no more than 35 percent …
Motorboat racing organization lost exemption for recreational and private purposes
A motorboat racing organization claimed exemption for fostering national or international amateur sports competition. Its articles permitted any lawful purpose and lacked a qualifying dissolution prov…
Condominium association denied section 501(c)(4) status
A condominium association collected owner assessments to pay for utilities, insurance, landscaping, parking, roofing, pest treatment, and other common-property expenses. Membership and voting rights w…
Business-park association denied section 501(c)(4) status
An association managed the common areas, design rules, construction review, and owner assessments for a privately owned commercial business park. Its members were the property owners, and a developer …
Homeowners association denied section 501(c)(3) status
A small homeowners association collected monthly fees from four members and used the pooled funds for property insurance and gardening. Its submitted articles bore a different name, did not establish …
Statehood advocacy group denied section 501(c)(3) status
An organization created educational websites, classroom materials, teacher seminars, videos, and civics resources about democracy and equality for a political unit. It also promoted statehood for that…
Gated condominium association denied section 501(c)(4) status
A condominium association collected monthly dues to maintain a gated building’s common areas and structural elements. Membership was limited to unit owners, who owned the common areas, and the buildin…
Health-care provider network denied business-league exemption
A health-care provider network sought exemption as a business league under section 501(c)(6). Its activities included coordinating therapy services and professional standards, but it also planned to n…
Young-professionals group failed the charitable organization tests
A membership organization for young nonprofit professionals applied for exemption under section 501(c)(3). It offered professional development, networking, social events, and advocacy intended to make…
Disability trust failed to establish charitable status
A purported trust sought section 501(c)(3) status for programs intended to help disabled people move toward self-support. It refused repeated requests for a complete signed trust agreement, declined t…
Volleyball officials association denied business-league exemption
An association of volleyball officials sought exemption as a business league under section 501(c)(6). It trained officials and promoted consistent officiating, but it also coordinated, scheduled, and …
Business-referral group denied business-league exemption
A networking group for owners from different professions sought exemption as a business league under section 501(c)(6). It held weekly meetings where members learned about one another's businesses and…
Charitable lead trust termination avoided private-foundation tax
A testamentary charitable lead annuity trust paid an escalating quarterly annuity to a charity, later divided between two successor foundations, with the remainder passing to the grantor's children. T…
Real estate brokerage denied charitable exemption
A stock corporation applied for section 501(c)(3) status while operating a commission-based residential real estate business led by its sole employee and director. It described a future apprentice pro…
Condominium association denied social-club exemption
A seven-unit condominium association sought exemption as a social club under section 501(c)(7). Membership automatically followed ownership of a unit, and member dues paid for lawn care, snow removal,…
Member hardship-benefit association denied charitable exemption
An association collected annual dues and automatically paid fixed benefits to members or their immediate families after specified events, including a death, an immigration arrest, a prolonged illness,…
Business-member organization denied charitable exemption
An organization sought recognition as a section 501(c)(3) charity for programs serving minority-owned and women-owned businesses. It offered workshops and entrepreneurship education, but it also provi…
Foundation lost exemption for commercial management activities
A private foundation had been formed to assist underprivileged children but also managed commercial and residential rentals and an automobile repair shop. The examination report said the foundation pe…
Homeowners association loses section 501(c)(4) exemption
The IRS revoked a homeowners association's section 501(c)(4) exemption for a self-declared tax year. The association repeatedly failed to answer IRS requests for records about its receipts, spending, …
Health-services ministry loses exemption for commercial activity and private inurement
The IRS revoked the section 501(c)(3) exemption of an organization that presented its health-services practice as a church ministry. The organization charged for services, received payments through in…
Fraternity housing club lost section 501(c)(7) exemption
The IRS revoked a fraternity housing corporation's section 501(c)(7) social-club exemption because rental of its fraternity house was its only activity and source of income, with no income from member…
Charity reclassified as private non-operating foundation
An organization remained exempt under section 501(c)(3), but the IRS changed its foundation classification from a section 509(a)(2) publicly supported organization to a private non-operating foundatio…
Farmers market lost section 501(c)(3) exemption
The IRS revoked a farmers-market organization's section 501(c)(3) exemption on both organizational and operational grounds. Its articles lacked the required dissolution clause, and a later amendment t…
Marketing consultancy denied section 501(c)(3) status
An organization sought section 501(c)(3) status to provide business-development and marketing consulting, principally for nonprofits and public-works organizations. The IRS found that its services wer…
Missing organizing provisions caused exemption revocation
An organization received section 501(c)(3) status after attesting on Form 1023-EZ that its organizing document contained the required limits on purpose and disposition of assets at dissolution. During…
Commercial medical equipment business lost exemption
A section 501(c)(3) organization operated two off-premises stores that sold and rented durable medical equipment to the general public at competitive commercial prices. Although it offered charity car…
Missing organizing documents caused exemption revocation
An organization obtained section 501(c)(3) status through Form 1023-EZ after attesting that its organizing document contained the required limits on purpose and disposition of assets at dissolution. D…
Soccer referee association denied section 501(c)(6) exemption
An association of soccer referees applied for exemption as a business league under section 501(c)(6). It trained and evaluated referees, but its primary activity was scheduling members for games, coll…
Charity exemption retroactively revoked for misstatements, lobbying, and illegal activity
The IRS retroactively revoked a corporation's section 501(c)(3) exemption after finding that its original application materially misstated how it would operate. The examination report said the organiz…
Dissolving foundation's asset transfer qualifies as an unusual grant
A publicly supported charity serving injured special-operations veterans asked whether it could exclude a large transfer from its public-support calculation as an unusual grant. A dissolving foundatio…
Family-specific orphan fundraiser denied section 501(c)(3) status
An unincorporated association applied for section 501(c)(3) status to hold a fundraiser for five children from one family after both parents died. The planned event would use all raised funds to offse…
Gated homeowners association denied section 501(c)(4) exemption
A gated homeowners association sought recognition as a tax-exempt social welfare organization under section 501(c)(4). Its activities included maintaining private roads, common areas, recreational fac…
What these documents are
- Private letter rulings (PLRs): A taxpayer asked the IRS to rule on a planned transaction before doing it. The ruling shows exactly how the IRS applied the Code to those facts.
- Technical advice memoranda (TAMs): The IRS National Office answering a question raised during an audit or other proceeding.
- Chief Counsel advice (CCAs): IRS lawyers advising their own field staff on how to apply the law.
- Determination letters: Rulings on exempt-organization matters, such as whether an organization qualifies under § 501(c)(3) or a foundation's grant procedures pass § 4945.
- Not precedent, still useful: Under 26 U.S.C. § 6110(k)(3) none of these can be cited as precedent. They remain the best public window into how the IRS actually rules on facts like yours, and practitioners read them for exactly that.